Marion Lane website privacy statement as at March 2018
White Home Group Pty Ltd (ABN 52 123 940 081) (WHG) is the holder of NSW Real Estate Corporate Licence (licence number 1484626) and QLD Real Estate Licence (4065008). White Home Group Pty Ltd is a Corporate Credit Representative of Australian Credit License number 482276, Corporate Credit Representative Number 422528. Marion Lane is a trading name of White Home Group Pty Ltd. In this document, any reference to ‘White Home Group’, ‘Marion Lane’, ‘we’, ‘us’ and ‘our’ are references to White Home Group and any related bodies corporate.
Our commitment to you
We understand how important it is to protect your personal information. This policy explains how your personal information will be treated, including when you access and interact with this website. A reference to ‘this website’ or ‘our website’ includes any websites (including any microsites and mobile websites) operated by or on behalf of Marion Lane Pty Ltd (details below) and its related bodies corporate. This policy also explains how we will collect and manage your personal information.
Our commitment in respect of protecting your privacy is to abide by the Australian Privacy Principles for the protection of personal information, as set out in the Privacy Act 1988 (Cth) and any other relevant law.
We review this policy periodically and we will amend our policy as the need arises, such as to reflect emerging legislative and technological developments, industry practice and market expectations. We will let you know of any changes to this policy by informing you via our website.
What is personal information?
What personal information do we collect and hold?
Your personal information and its protection are of utmost importance to us. Personal information held by us may include your name, age or date of birth, current and previous addresses, telephone or mobile phone numbers, email addresses, occupation, qualifications and any additional information you provide to us directly, through our website, or indirectly through the use of our website or online presence, through our representatives or otherwise information you provide to us through our onsite centre, customer surveys or visits by our representatives from time to time. We may hold details of products and services (including their status) you have, such as your existing property, your home loan, car finance or superannuation provider.
How we collect personal information
We collect personal information in a number of ways, including:
directly from you, for example, when you provide information by phone, letter or email; in application forms or other agreements; when you submit your personal details through any of our online platforms; during conversations between you and our representatives; by entering competitions, promotions or requesting information or material from us; completing surveys, providing feedback or complaining to us
from third parties such as your representatives (lawyers, accountants and financial advisers); your employer; providers of survey, competition or marketing related services, related companies. If we obtained your information through any of these methods and you would like a list of these entities or websites, or if you feel you have not given us consent to use your details, please contact us using the details below;
from publicly available sources of information;
from the organisations and entities identified under ‘When we disclose your personal information’;
from our own records;
when you visit any of our online platforms; and
when legally required to do so – for example, from credit reporting agencies, law enforcement agencies and government entities
How we use your personal information
Your personal information may be used to:
provide products and services to you and to send communications requested by you
answer enquiries and provide information or advice about existing and new products and services
provide you with access to our protected areas of our website
assess performance of the website and to improve the operation of the website
inform you of ways the products and services provided to you could be improved or additional products or services that you may benefit from;
market products or services (explained below);
research and develop our products or services provided, either directly or referred;
gain an understanding of your information or needs in order for us to provide you with a better service.
If you choose not to provide certain personal information (for example, your date of birth), we may not be able to provide you with the products and services you require, or the level of service on which we aim to offer.
Also, your personal information is collected so that we can promote and market products and services to you (including by way of direct mail, telemarketing, email, SMS and MMS messages and via social media). This is to keep you informed of products, services and special offers and this may continue after you cease holding an active product or service through us. If you do not wish for this to take place or continue, please contact us below.
When we disclose your personal information
We will not sell, trade or rent your information to any party outside of White Home Group. In order to deliver the products or services you require, we may disclose your personal information to organisations outside of White Home Group. Your personal information is disclosed to these organisations only in relation to us conducting our business or providing our products and services to you. In particular, we will disclose personal information about you to our employees, related body corporate, contractors or service providers for the purposes of operation of our website or our business, fulfilling requests by you, and to otherwise provide products and services to you including, without limitation, web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators, debt collectors, and professional advisors such as accountants, solicitors, business advisors and consultants. We will also disclose personal information about you to suppliers and third parties with whom we have commercial relationships, for business, marketing and related purposes.
We may use external organisations to carry out or handle our:
billing and debt-recovery functions;
information technology services;
marketing and telemarketing
website usage analysis; and
other business needs from time to time.
This means we disclose your personal information (such as name and address) to them. We take reasonable steps to ensure that these organisations are bound by confidentiality and privacy obligations in relation to the protection of your personal information.
In addition, we may disclose your personal information to:
anybody who represents you, such as finance brokers, lawyers and accountants;
our professional advisers, including our accountants, auditors and lawyers;
investors, agents or advisers, or any entity that has an interest in our business;
comparison sites, mortgage brokers or providers of investment, finance or credit where it is legal for us to do so;
organisations who manage our business, marketing, corporate or related strategies;
organisations that provide information and infrastructure systems to us;
organisations that provide products or services used or marketed by us;
associated businesses that may want to market products and services to you; or
anyone, where you have provided us consent.
Some of the above external organisations and entities may be located outside of Australia.
Transfer of information overseas
We currently run our business in Australia, but this may be expanded to other countries. We will provide a list of these countries by updating this policy.
We may need to share some of your information (including credit information) with organisations outside Australia, including the Philippines and the USA. You should note that while they will often be subject to confidentiality or privacy obligations, they may not always follow the particular requirements of Australian privacy laws. In the event that a disclosure is made in an overseas country (which we consider unlikely), the information will not be protected by the Australian Privacy Principles. In any event, by providing your details, you consent to your information being disclosed in this manner. Overseas organisations may be required to disclose information we share with them under a foreign law. In those instances, we are not responsible for that disclosure.
We may store your information in cloud or other types of networked or electronic storage. You should note that, as electronic or networked storage can be accessed from various countries via an internet connection, it is not always practicable to know in which country your information may be held.
Sensitive information is any information about your racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual preferences or practices, criminal record or health information.
We may seek, collect, use or disclose sensitive information about you, but only if that sensitive information relates directly to our ability to conduct our business, arrange or provide services to you.
We may use or disclose your personal information to let you know about products and services from us and our agents, business partners and affiliates that might be of interest to you (such as by way of updates or newsletters), to run competitions or promotions and to communicate other offers or opportunities in which you may be interested.
We may conduct these marketing activities via mail, email, telephone, messaging such as SMS and MMS, or any other means, including electronic means, in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth). We may also market our products and services to you through third party channels (such as social networking sites). We will always let you know that you can opt out from receiving marketing offers. If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so.
With your consent, we may disclose your personal information to third parties such as brokers or agents, or for the purpose of connecting you with other businesses or customers. You can ask us not to do this at any time.
Third party marketing service providers may combine the personal information we disclose to them with information they already hold about you, in order to provide you with more relevant advertising about our or their products and services.
We will not use or disclose sensitive information about you for direct marketing purposes unless you have consented to that kind of use or disclosure.
Where we market to prospective customers, we are happy to let them know how we obtained their information and will provide easy to follow opt-outs.
IP address, cookies and web beacons
Your internet protocol address (or ‘IP address’) is the numerical identifier for your device when you are using the internet. It may be necessary for us to collect your IP address for your interaction with some parts of our website.
Cookies (and targeting and remarketing)
A web beacon is typically a transparent graphic image invisible to the user that is placed on a website. The use of a web beacon allows the website to record the simple actions of the user (such as opening the page that contains the beacon) through a tracking pixel.
We may use web beacons (and cookies) for purposes such as site usage analytics, advertising auditing and reporting, as well as content and ‘advertising/marketing personalisation’. We may share any data collected from web beacon (and cookies) with third parties to provide you with relevant advertising when browsing Third Party Websites.
Information from third parties
Our website may contain links to Third Party Websites (for example, third party providers of goods and services). If you accessed Third Party Websites through our website and if those third parties collect information about you, we may also collect or have access to that information as part of our arrangements with those third parties.
Where you access a Third Party Website from our website, cookie and web beacon information, information about your preferences or other information you have provided about yourself may be shared between us and the third party.
Advertising and tracking
When you access our website after viewing one of our advertisements on a Third Party Website, the advertising company may collect information on how you utilise our website (for example, which pages you viewed) and whether you commenced or completed an online application or other online forms.
When you send a completed online application to us, we retain the information contained in that application. We are able to then use that information to provide any products and services that you require.
You may also be able to suspend and save online applications, so you can complete and send the applications at a later time. If you suspend or save your application, the information that you have entered will be retained in our systems so that you may recover the information when you resume your application. Online applications that have been suspended or saved may be viewed by us. In particular, if you start but do not submit an online application, we can contact you using any of the contact details you have supplied to offer help completing it.
We take all reasonable precautions to ensure that the personal information we collect, use and disclose is accurate, complete and up-to-date.
However, the accuracy of that information depends to a large extent on the information you or others provided to us.
Update and access of personal information
If you wish to make any changes to your personal information, please contact us. We will generally rely on you to assist us in informing us if the information we hold about you is inaccurate or incomplete.
You may request access to the personal information we hold about you by contacting us. We will respond to your request within a reasonable period. We will give access in the manner you have requested if it is reasonable to do so. We may charge you a fee to access the information. The fee will not be excessive and will not apply to the making of the request.
We may deny you access to your personal information in certain circumstances, for example, if required or authorised by or under an Australian law or a court/tribunal order, or it would be likely to prejudice enforcement related activities by an enforcement body. In relation to credit eligibility information, the exceptions may differ.
If we decide not to give you access, we will provide reasons for the refusal and information on how you can complain about the refusal.
Helping you manage corrections
Whether we made the mistake or someone else made it, we are required to help you ask for the information to be corrected. So we can do this, we might need to talk to others. However, the most efficient way for you to make a correction request is to send it to the organisation that made the mistake.
Where we correct information
If we are able to correct the information, we will let you know within five business days of deciding to do this. We will also let the relevant third parties know as well as any others you tell us about. If there are any instances where we cannot do this, then we’ll let you know in writing.
Where we cannot correct information
If we are unable to correct your information, we will explain why in writing within five business days of making this decision. If you have any concerns, you can access our external dispute resolution scheme or make a complaint to the Office of the Australian Information Commissioner (OAIC).
Time frame for correcting information
If we agree to correct your information, we will do so within 30 days from when you asked us, or a longer period that’s been agreed by you.
If we cannot make corrections within a 30 day timeframe or the agreed time frame, we must:
let you know about the delay, the reasons for it and when we expect to resolve the matter;
ask you to agree in writing to give us more time; and
let you know you can complain to our external dispute resolution scheme or the OAIC.
Storage and security of personal information
We store information in different ways, including in paper and electronic form. The security of your personal information is important to us and we take reasonable steps to protect it from misuse, interference and loss, and from unauthorised access, modification or disclosure. Some of the ways we do this are:
confidentiality requirements of our employees;
document storage security policies;
security measures for access to our systems;
only giving access to personal information to a person who is verified to be able to receive that information;
control of access to our buildings; and
electronic security systems, such as firewalls and data encryption on our website.
We may store your information in cloud or other types of networked or electronic storage. As electronic or networked storage can be accessed from anywhere via an internet connection, it is not always practicable to know in which country your information may be held. If your information is stored in this way, disclosures may occur in countries other than those listed here or those we referred to from time.
In addition to the above, we also regularly review developments in security and encryption technologies. However, it is important to remember that the use of email and the internet may not always be secure, even with these safeguards in place.
When we no longer require your information, and we are legally permitted to, we take reasonable steps to destroy or de-identify the information. However, sometimes it is impossible or impractical to completely isolate the information then completely remove all traces of the information, and we may store the information for future use, such as to help resolve disputes between us or assess future applications by you. The same security safeguards will be in place to protect the information, as detailed in this policy.
Business without identifying you
In most circumstances, it will be necessary for us to identify you in order to successfully do business with you. However, where it is lawful and practicable to do so, we will provide you with the option to remain anonymous or to use a pseudonym, for example, when you make general inquiries about our business or current promotional offers.
We do not adopt a government related identifier (such as your tax file number or your driver’s licence number) as a means of identifying you.
How to contact us
You may contact us during AEST business hours by telephone by calling 1300 494 483, via post at PO Box Q689, QVB, NSW 1230 , or by email email@example.com.
Complaints and further information
If you have a complaint about how we handle your personal information, we want to hear from you. You are always welcome to contact us.
You can let us know about your complaint or feedback by contacting us at:
The [General Manager]
PO Box Q689, QVB, NSW, 1230
Telephone: 1300 494 483
By giving us as much information as possible, you will help us resolve things faster. And if you have any supporting documentation, please have it handy when you raise your concern. Most complaints are resolved quickly and you should hear from us within five business days.
If you are dissatisfied with our response, you may make a complaint to the OAIC which can be contacted on either www.oaic.gov.au or 1300 363 992.
You may request further information about the way we manage your personal information by contacting us.
Our website may contain links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website. Third party websites are responsible for informing you about their own privacy practices.